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Home My WebLink About99-07039 ?I 49 i, !. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. d N'4Laa'A .. PATRICIA A. VAUGHN Plaintiff N O. 1999-07039 Civil VERSUS STEVEN K_ VAUGHN Defendant DECREE IN DIVORCE AND NOW, YJ I O 2000 , IT IS ORDERED AND DECREED THAT Patricia A. Vaughn PLAINTIFF, Steven K. Vaughn AND DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OFTHE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; BY THE COURT: ATTES J. PROTHONOTARY i?. I' PATRICIA A. VAUGHN, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 1999-07039 STEVEN K.VAUGHN, CIVIL ACTION-LAW Defendant IN DIVORCE PRA ECIPE TO TRANSMIT RECORD THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a Divorce Decree: 1. Ground for divorce: Irretrievable breakdown under Section (X) 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: November 27, 1999 3. (Complete either paragraphs (a) or (b). (a) Date of execution of the Affidavit of Consent required by Section 330l(c) of the Divorce Code: by Plaintiff: March 13, 2000 by Defendant: April G, 2000 (b) (1) Date of execution of the Plaintiffs Affidavit required by Section 3301(d) of the Divorce Code: (2) Date of service of the Plaintiffs Affidavit upon the Defendant: 4. Related claims pending: No economic claims have been raised. 5. (a) Date and manner of service of the notice of intention to file Praecipe to transmit record, a copy of which is attached: (b) Date of Plaintiffs Waiver of Notice in 3301(c) Divorce was filed with Prothonotary: March 28, 2000 Date of Defendant's Waiver of Notice in 3301(c) Divorce was filed with the Prothonotary: Filed contemporaneously ?; - 1 . ? _ +J ' (; `. IJ _' ,•) ' _ C-: 0.., _ : ??V !: . L: _ ?.) ? PATRICIA A. VIAUGHN, Plaintiff VS. STEVEN K. VALTGHN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. qq _ 7039 (? t o.<,L CIVIL ACTION-LAW IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you vvish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that ff you fail to do so, the case may pYoceed without you and a decrae of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plairatiff. You may lose money or property or other rights ini-portant to you, including custody or visitation of your children. When the ground for the divorce is indignitdes or irretrievable breakdown of the marriage, you array request marriage counseling. A list of marriage counselors is available in the Office off the Court Administrator, Cumberland County Courthouse, Hanover Street, Carlisle, PA. IF YOU DO SLOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DIVORCE OF, ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM_ YOU SHOUZD TAKE THIS PAPER TO YOU-:R LAWYER AT ONCE. IF YOU DO NOT HAVE A FO TH LAV% TO FIND OUT WHERE YOU CEANO ET OR O LEGAL HELP NE THE OFFICE SET Cumberland County Bar Association 2 Liberty Avenue Carlisle, TA 17013 (717) 249-3166 PATRICIA A. VAUGHN, PlainLiff VS. STEVEN K. VAUGHN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. (7S_17 6L9C?C?? %tw CIVIL ACTION-LAW IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN NAMED DEFENDANT: You have been named as the Defendant in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with §3302(c) or (d) of the Divorce Code, youmay requestthat the Court require you and your spouse to attend marriage counseling priorto a divorce decreebeing handeddown by the court. A list of professional marriage counselors is available at the Cumberland County Court House, Carlisle, Cumberland County, Pennsylvania. You are advisedthat this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. PROTHONOTARY Dated: PATRICIA A. VAUGHN, Plaintiff VS. STEVEN K. VAUGHN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. % I - 70 3 / ect-v -nc CIVIL ACTION-LAW IN DIVORCE COMPLAINT 1. The Plaintiff Patricia A. Vaughn, is an adult individual whose residence is 331 Thud Street, New Cumberland, Cumberland County, Pennsylvania 17070. 2. The Defendant Steven K. Vaughn, is an adult individual whose residence is 4418 Derry Street, Harrisburg, Dauphin County, Pennsylvania 17111. 3. The Plaintiff has been a boaafide resident in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on June 10, 1995, in Camp Hill, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. The Plaintiff avers that there are no children of the parties under the age of 18. 7. The Plaintiff in this action is not a member of the Armed Forces. 8. The Plaintiff and the Defendant are citizens of the United States. 9. The Plaintiff has been advised of the availability of marriage counseling and that she may have the right to request the court to require the parties to participate in such counseling. Being so advised, Plaintiff does not request that the court require the parties to participate in counseling prior to a divorce decree being handed down by the court. 10. The Plaintiff avers the grounds on which the action is based is that the marriage is irretrievably broken. WHEREFORE, the Plaintiff requests the Court to enter a decree of divorce. Respectfully submitted, PURCELL, KRUG & HALLER BY J W. Ptdell, Jr., Es( I IV. #29955 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 VERIFICATION I verify that the statements made in the foregoing Complaint in Divorce are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 5 4904, relating to unsworn falsification to authorities. Dated: )\\ ?) ? "1'1 Patricia A. Vaughn PATRICIA A. VAUGHN, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 1999 - 07039 STEVEN K. VAUGHN, : CIVIL ACTION-LAW Defendant : IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) ss: COUNTY OF DAUPHIN 1, Carol Masich, secretary to JOHN W. PURCELL, JR., Attorney for the Plaintiff in the above action, hereby swear and affirm that on the 23id day of November, 1999, 1 sent, by certified mail, return receipt requested, deliver to addressee only, a certified copy of the Complaint in Divorce, containing Notice to Defend and Claim Rights to Steven K. Vaughn, the Defendant in the above action. The return receipt, duly signed by the Defendant is attached hereto and made a part hereof as Exhibit "A" Carol Masich Sworn and subscribed to before me this day of 1V0l]FM1bF2 , 1999. BARBARA A. SHADE1, Notary Public Harrisburg, Dauphin County My Commiselon Expires March t?. 2003 Z LL95 294 996 us Postal Service Receipt for Certified Mail No Insurance Coverage Provided. Postage $ Conrad Fee Special Delivery Fee plastered Delivery Fee m Return Receipt Showing to d Who, YJham BDale Delivered 'a Ream RaeiptSo0Wgl0W-- < Dale.6 Addressees Mi- d TOTAL Postage B Fees $ Q() PosMaM or Date N a I, m SENDER: Iq 0 W*Qle item 1 snorer 210 addeteail "'vii" (,' 1Q Oonplots Items 3. ra. ene rb. C' p prior your meet, and address on Ne rwaroo of Ibis torte eo Nalwe coe relem lNs is cad to you. net tm OAnech this Corm to me front of em mwlpleco. or on the barkll icy) m p9md1. .$ ?yarte 'Karam Rocelpr Roguosfed'onlha C 13 It* wFlowm Receipt war show to where th 0 3, tlcte Addressed to: 6 Y- U''61 5. Received BY (Pdnt Name) c 8. Sig nureAe dyes a rAgent > e LC m pS Form 3811, December 1994 i I also wtsh to receive the follow- ing services (for an extra fee): 1. ? Addressee's Address 2PReseided Delivery 7 press Mall -10F r 113 Return Futcall' `? \ ? ? 7. Date of Deliry is paid) Exhibit "A" 102595.990-0223 1 i i m I u I r? I I al I c ! mi .? I 0 I m I T C I I i rt I I 4 C. Eck L,3 i u .2w .2 u0- F . c O s C ) - , r PATRICIA A. VAUGHN, Plaintiff VS. STEVEN K. VAUGHN Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 1999-07039 : CIVIL ACTION-LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1 . A Complaint in Divorce under Section 3301(c) of the divorce Code was filed on November 22, 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. 1 consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE 1 . I consent to the entry of a final decree of divorce without notice. 2. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. 1 understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is filed with the prothonotary. verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. Date: Patricia A. Vaughn C ' - L -. D fl: ? a) ?-'stn _ . ,a u o v IT PATRICIA A. VAUGHN, Plaintiff VS. STEVEN K. VAUGHN Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999-07039 CIVIL ACTION-LAW IN DIVORCE AFFIDAVIT OF CONSENT 1 . A Complaint in Divorce under Section 3301 (c) of the divorce Code was filed on November 22, 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. 1 consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE 1 . I consent to the entry of a final decree of divorce without notice. 2, 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. 1 understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is filed with the prothonotary. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. Date: 6-,AY 4: Steven K. Vaughn !r> t^ -? :.:.:! ? N :_?; ?. G. .?. J C) ? ._? ?.,.r?... PATRICIA A. VAUGHN, Plaintiff vs. STEVEN K. VAUGHN, Defendant TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999-07039 CIVIL ACTION-LAW IN DIVORCE PRAECIPE The Social Sec,.. ity Number of the Plaintiff is 175-48-2961, and the Social Security Number of the Defendant is 327-38-9135. Respectfully submitted, PURCELL, KRUG & HALLER BY 1 n W. Purcell. Jr. Y119 North Front Street Harrisburg, PA 17102 Attorney for the Plaintiff tot( C1 O U